UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 
FERDINAND J. MACK 
ATTORNEY AT LAW 
SUITE 106 
OLD TOWN CENTER 
17 WEST JEFFERSON ST. 
ROCKVILLE. MARYLAND 
SOHOO 
FERDINAND J. MACK, JR. 
an infant 
Plaintiff 
v 
JOSEPH A. CALEFANO, JR. et al 
Defendants 
FILE ET' 
JAN 1 2 1970 
JAMES E. DAVEY, Cleri 
Civil Action No. 77-0916 
Judge John Lewis Smith, Jr. 
SUPPLEMENTAL MEMORANDUM OF POINTS AND AUTHORITIES 
IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION AND 
IN OPPOSITION TO VACATION OF STAY 
1. This action started out as an endeavor to compel the defendants 
to file an environmental impact statement before they commenced the 
proposed Risk Assessment Studies at Ft. Detrick, Frederick, Maryland 
As the Court is aware, defendants have stipulated that the experiments 
will not proceed until an environmental impact statement is prepared. 
Thus, the issue is no longer whether an environmental impact statement 
should be prepared in connection with these experiments; the issue is 
whether a legally sufficient environmental impact statement has been 
prepared. 
2. The questions confronting the Court in reviewing the 
environmental impact statement filed by defendants are: (1) Is the 
environmental impact statement on guidelines for all DNA research one that 
addresses the proposed Risk Assessment Studies? and (2) Does the 
statement comply with the requirements of NEPA? 
I 
3. The defendants concede that the environmental impact statement j 
does not address itself specifically to the Ft. Detrick Risk Assessment 
Studies: 
301 870-2230 
[Appendix C — 125] 
